https://www.taxtmi.com/caselaws?id=148307 Delegated rule-making power could not validly impose a three-month limitation period for refund applications where the parent statute prescribed no limitation and did not expressly or necessarily imply authority to create one. The limitation rule was therefore invalid, requiring the refund applications to be considered on merits. Under the unamended refund provision, prior actual payment or collection of tax was not a condition for claiming refund because it referred only to tax levied. The later amendment requiring tax to be levied and collected introduced a new condition and could not govern applications made before it took effect. en-us Fri, 10 Mar 1967 00:00:00 +0530 Thu, 25 Apr 2013 15:00:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=148307 Delegated rule-making power could not validly impose a three-month limitation period for refund applications where the parent statute prescribed no limitation and did not expressly or necessarily imply authority to create one. The limitation rule was therefore invalid, requiring the refund applications to be considered on merits. Under the unamended refund provision, prior actual payment or collection of tax was not a condition for claiming refund because it referred only to tax levied. The later amendment requiring tax to be levied and collected introduced a new condition and could not govern applications made before it took effect. Case-Laws VAT and Sales Tax Fri, 10 Mar 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=148307